Tranche 2 confirmed: independent evaluations to be staggered by AUSTRAC account number
What’s new: AUSTRAC has confirmed that the first round of independent evaluations for newly‑regulated tranche‑2 businesses will be staggered. The deadline you receive will be determined by the AUSTRAC account number issued to you when you enrol. The earliest evaluation deadline is 1 July 2029, with subsequent cohorts at six‑month intervals thereafter.
This mechanism is designed to prevent bottlenecks—so entire sectors (e.g., real estate) or business types (e.g., small practices) aren’t all due at the same time.
Who is captured under Tranche 2 and when?
From 1 July 2026, AML/CTF obligations commence for entities providing designated services in the following sectors: real estate, law, conveyancing, accounting, trust & company services, and dealers in precious metals and stones. Enrolment opens 31 March 2026.
AUSTRAC’s reform hub provides the consolidated timeline, guidance, and sector resources to prepare for these changes.
The staggered evaluation model: how it works
Extended first‑evaluation deadline set by AUSTRAC account number: When you enrol from 31 March 2026, you’ll receive an AUSTRAC account number. AUSTRAC will use that number to assign your first independent evaluation deadline, ensuring a spread across sectors and business sizes. You may embed this extended deadline in your AML/CTF program if it suits your nature, size and complexity.
Earliest first deadline = 1 July 2029: No newly‑regulated business will be required to complete its first independent evaluation earlier than three years from commencement. AUSTRAC sets the first tranche‑2 deadline at 1 July 2029, with further cohorts at six‑month intervals (e.g., early 2030, late 2030, etc.), based on account number allocations.
If you’re already regulated (Tranche 1): Entities that recently completed a pre‑reform independent review will also receive an extended window for their first post‑reform evaluation, scaled to how recently they were reviewed.
Important: “Staggered” only applies to the timing of your first independent evaluation. It does not delay the start of your AML/CTF obligations from 1 July 2026 for tranche‑2 entities.
What Tranche 2 entities must do now (step‑by‑step)
Calendar the big three dates:
31 Mar 2026 (enrollment opens), 1 Jul 2026 (obligations begin), 29 Jul 2026 (Deadline to register).
Design and operate your AML/CTF program early: Build your risk assessment, AML Program, CDD, transaction monitoring, SMR processes, recordkeeping, and training—and start capturing evidence of effectiveness well before July 2026.
Add the evaluation clause to your program: Document that you will use the extended first‑evaluation deadline assigned by AUSTRAC account number, provided it’s appropriate to your nature, size and complexity. Keep a placeholder section to insert your actual date once you enrol and receive your number.
Build a capacity plan: Even with staggering, demand for independent evaluators will spike around each cohort date. Start short‑listing independent, appropriately qualified evaluators and request provisional windows that align with your expected cohort (you’ll confirm after enrolment).
Assign internal owners: Nominate a project lead, program author, training owner, and records custodian.
Prepare an “evaluation pack”: Keep a live folder with risk assessment versions, program updates, training logs, CDD samples, SAR/SMR decisioning memos, monitoring alerts, remediation logs and board/senior‑management oversight evidence—this is what evaluators and AUSTRAC will expect to see.
Frequently asked questions
When will I know my exact evaluation deadline?
After you enrol from 31 March 2026, AUSTRAC issues an account number. Your first independent evaluation deadline will be set off that number, with 1 July 2029 the earliest cohort and subsequent six‑monthly cohorts thereafter. Insert the confirmed date into your AML/CTF program once you receive it.
Can I elect to be evaluated earlier than my cohort?
You may plan an earlier evaluation in your program (e.g., for risk, client or governance reasons). The staggered model simply defines the latest acceptable first‑evaluation deadline tied to your account number.
The bottom line (and why starting early still matters)
Staggering will spread demand and reduce bottlenecks, but it won’t help if your AML/CTF program isn’t operating well before your evaluation window. Start now, so by the time your account‑number‑based deadline arrives, your program already works in practice and you have the evidence to prove it.
Need help?
👉 Book a Tranche 2 Readiness Session with AML Advisers today and see how we can assist you with your prep!
